2021 Rate Changes

Every year, I spend months painstakingly tracking every insurance carrier rate filing for the following year to determine just how much average insurance policy premiums on the individual market are projected to increase or decrease.

Carriers tendency to jump in and out of the market, repeatedly revise their requests, and the confusing blizzard of actual filing forms sometimes make it next to impossible to find the specific data I need. The actual data I need to compile my estimates are actually fairly simple, however. I really only need three pieces of information for each carrier:

  • How many effectuated enrollees they have enrolled in ACA-compliant individual market policies;
  • What their average projected premium rate increase (or decrease) is for those enrollees (assuming 100% of them renew their existing policies, of course); and
  • Ideally, a breakout of the reasons behind those rate changes, since there's usually more than one.
  • In 2015, I projected that the overall average rate increases for 2016 would be roughly 12-13% nationally. It turned out to be around 11.6%.
  • In 2016, I projected that the overall average rate increases for 2017 would be roughly 25% nationally. It turned out to be around 22%, but that only included on-exchange Silver plan enrollees across 44 states (I included all metal levels, both on and off exchange, across all 50 states).
  • In 2017, I projected that the overall average rate increases for 2018 would be around 29% nationally, and that 60% of that would be due specifically to deliberate Trump Administration actions designed to sabotage the ACA markets. It turned out to be around 28% nationally.
  • In 2018, I projected that the overall average rate increases for 2019 would be around 2.8% nationally, and that premiums would have dropped around 5.4% on average if not for the ACA's individual mandate being repealed & short-term & association plans being expanded. Hhealthcare think tank Avalere Health came to almost the exact same estimates on the actual rate changes, while Brookings Institute healthcare analyst Matthew Fiedler concluded that unsubsidized ACA individual market premiums would indeed have dropped by around 4.3% nationally on average in the absence of mandate repeal and expansion of #ShortAssPlans.

In other words, I've had a pretty good track record of accurately projecting average premium increases for the upcoming year for five years in a row. With that in mind, below you'll find a table tracking the state-by-state preliminary and final rate changes for the 2021 ACA-compliant individual (and sometimes small group) markets. Scroll down for individual state entry links.

For 2021, the biggest new factor is, of course, the impact of the COVID-19 pandemic on both 2020 and 2021 medical claims expenses. I've added a new column which attempts to separate that out, though not every carrier does so, while some simply refer to the impact of COVID-19 in a fairly vague way.

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I'm not sure what's going on with Bright Health Care in Nebraska. They entered the state's ACA market in 2020, but for whatever reason they aren't showing up in the HealthCare.Gov Rate Review database. The only carrier listed for the state's individual market is Medica, and the SERFF database for Nebraska doesn't bring up either one.

Even more curious, when I ran a search to make sure that Bright hadn't simply jumped in and then out again the following year, I found this article:

Bright Health Plan announced today its 2021 expansion plan. It will expand access to its Medicare Advantage, individual and family-plan products in select areas, and to add fully-insured small business plans to its available products in certain markets.

I don't know if this is an industry trend, a state regulator trend or new policies being implemented by CMS, but it seems that either more health insurance carriers have been redacting their Actuarial Memos and/or not uploading their URRT files to the publicly-accessible SERFF database or the state insurance departments, SERFF database and/or CMS's Rate Review database aren't posting as many of them publicly.

Case in point, Wisconsin: I have the average requested 2021 premium rate filings for every carrier on the individual and small group markets...but the actuarial memos are all redacted and none of the URRTs are available at all, making it impossible for me to run a weighted average since I don't know how many enrollees each carrier has. Also, for the second year running, Compcare Health Services doesn't appear in CMS's Rate Review database at all for reasons unknown.

Missouri's preliminary avg. 2021 unsubsidized premium rate changes have been posted. There's one new entrant into the individual market this year (Blue Cross Blue Shield of Kansas City, which actually mostly pulled out of MO a couple of years back). Nothing too noteworthy--the average requested 2021 premium is going up 4.7% on the individual market and 9.3% on the small group market.

The Indiana Insurance Dept. has posted their 2021 individual & small group rate filings to the SERFF database. Nothing terribly noteworthy other than the average requested rate increase is unusually high for 2021 compared to most other states so far (10.2%, mainly via Celtic), and it looks like a second division of UnitedHealthcare is offering policies on the small group market next year:

Back in July, the Connecticut Insurance Dept. posted the preliminary 2021 rate filings for the individual and small group market carriers. On average, they were seeking rate increases of 6.3% for the individual market and 11.3% for the small group market.

Today, the CT DOI issued their final rate change rulings, and the difference are pretty dramatic:

Insurance Commissioner Issues Decisions For 2021 Health Insurance Rates

Insurance Commissioner Andrew N. Mais today announced the Department has made final decisions on health insurance rate filings for the 2021 coverage year. As a result of these decisions, approximately 214,600 Connecticut consumers are projected to save $96 million.

The Department approved an average increase for individual plans of 0.01 percent, down from the average request of 6.29 percent. The average increase for small group plans is 4.1 percent, down from the requested average of just over 11.28 percent.

Hmmm...on the one hand, this summary of the 2021 ACA individual market rate filings from the Ohio Insurance Dept. would appear to be pretty straightforward:

The sections below include a summary of Ohio’s individual market for 2021.  The data is based on product filings the Ohio Department of Insurance is currently reviewing.

Ohio’s Health Insurance Market 2021

For 2020, the department approved 10 companies to sell on the exchange. Based on the plan information the department approved, most counties had at least three insurers.  29 counties had two insurers, and just one county had only one insurer.

For 2021, the department approved those same 10 companies to sell on the exchange.  Based on those filings, all counties will have at least two insurers and all but 10 counties will have three or more insurers. 

Companies Who Have Filed to Sell in 2021

Exactly one month ago, I posted an analysis of the preliminary 2021 premium rate filings for Georgia's individual and small group market carriers. At the time, the requests from the individual market carriers ranged from a 22.8% reduction to as much as an 18.3% increase.

I've also repeatedly noted that estimates by the carriers of the impact of the COVID-19 pandemic is pretty much all over the place. While a few carriers have indeed baked in significant rate hikes in response to COVID, most either don't mention it at all in their preliminary filings or, if they do, state that they expect the net impact to be negligible. However, they also make sure to hedge their bets by reserving the right to re-file their 2021 requests with adjusted COVID impact.

Overall, as I noted way back in May, the consensus on COVID-19 impact seems to be a big old ¯\_(ツ)_/¯.

via the Oklahoma Insurance Dept:

Oklahoma Consumers to Have More Health Options for 2021 ACA Plans

OKLAHOMA CITY – Insurance Commissioner Glen Mulready announced today the 2021 preliminary rate filings for health insurance plans under the Affordable Care Act (ACA). Insurers that currently offer coverage through the Oklahoma Marketplace filed plans requesting average statewide increases of 2.7 percent.

The same three insurers that offered individual health plans on the 2020 Exchange will return for 2021 — Blue Cross Shield of Oklahoma (BCBSOK) , Bright Health and Medica Insurance Company. In addition, Oscar Health, UnitedHealthCare (UHC) and CommunityCare Oklahoma (CCOK) will join the marketplace in Oklahoma for 2021 allowing consumers to have more choices. BCBSOK and Medica offer statewide plans while Bright Health, CCOK, Oscar and UHC serve limited areas of the state.

Moderate rate increase requests and new insurers looking to offer plans in Oklahoma revealed that the Oklahoma insurance market is stable and able to offer multiple health insurance options for all Oklahomans.

As I just noted with my Arizona post, the federal Rate Review database website heavily redacts the rate filing forms submitted by insurance carriers, making it impossible to run a weighted average even when all of the individual and small group market carrier rate change requests are readily available.

Fortunately, in the case of Florida, the Office of Insurance Regulation has at least provided the weighted average for me in each market, even though they still hide the actual enrollment numbers for each carrier:

The good news is that the federal Rate Review database has now posted the preliminary avg. 2021 rate filings for the individual and small group markets for every state. This makes it very easy to plug in the average requested rate changes in 2021 for every carrier participating in both markets.

The bad news is that most of the underlying filing forms are heavily redacted, meaning I can't use the RR database to acquire the other critical data I need in order to run a proper weighted average: The number of people actually enrolled in the policies for each carrier.

This means that in cases where this data isn't available elsewhere (either the state's insurance department website, the SERFF database or otherwise), I'm limited to running an unweighted average. This can make a huge difference...if one carrier is requesting a 10% increase and the other is keeping prices flat, that's a 5.0% unweighted average rate hike...but if the first carrier has 99,000 enrollees and the second only has 1,000, that means the weighted average is actually 9.9%.

via the New Hampshire Insurance Dept:

Large Decreases in 2021 Premium Rates Expected in Individual Market

CONCORD, NH – The federal government has published information on proposed rates for New Hampshire’s health insurance exchange (https://ratereview.healthcare.gov/) in 2021.

The New Hampshire Insurance Department is reviewing 2021 forms and rates for individual health plans. For 2020, the second lowest cost silver plan was $404.60. The 2021 second lowest cost silver plan proposed premium rate is $318.95. This represents a 21.2% decrease.

It's important to note that the 21.2% decrease only refers to the difference between the 2020 benchmark and the 2021 benchmark plans. They aren't necessarily from the same carrier, and even if they are, that's not the same as the weighted average rate changes for all policies at all metal levels from all carriers.

Back in late June, I noted that the Maine Insurance Dept. had issued the preliminary 2021 rate filings for the state's individual and small group market carriers. At the time, the individual market carriers were averaging rate reductions of around 4% while the small group carriers were looking to raise premiums by around 6.2%.

It was recently brought to my attention that revised rate filings have been submitted by Maine carriers for 2021...and while these still aren't the final/approved rates, they're significantly lower than the original filings.

Two of the three indy market carriers (Anthem and Harvard Pilgrim) have reduced their rates dramatically. The third (CHO) only reduced theirs by a couple of points, but the net result is that they're now averaging a 13% reduction...9 points lower than the 4 points they were already being knocked down.

The small group market carriers didnt' change their requests by as much, but they're still lower: A 4.4% average increase instead of 6.2%.

Virginia is usually the first state to publicly post their preliminary annual individual/small group market health insurance premium rate filings; historically they've published them as early as mid-April. This year, however, due primarily to the COVID-19 pandemic, I presume, they didn't actually post them until mid-August.

The average premium changes for 2021 on the individual market range from a 13% drop to a 7.7% increase, with the statewide weighted average coming in at around a 7.2% reduction. For the small group market, premiums are increasing by around 3.6% on average, ranging from a 2.4% drop to a 10.9% increase.

Two other noteworthy items: First, Optimum Choice is expanding into VA's individual market (this isn't the same as Optima Health); secondly, VA's indy market has dropped from over 300,000 last year to around 256,000 this year, presumably due to the lingering effects of Medicaid expansion enrollees shifting over from subsidized private plans.

The Delaware Insurance Dept. has posted the preliminary 2021 rate filings for the individual and small group health insurance markets.

The Indy market is about as simple as it gets since there's only a single carrier offering ACA policies either on- or off-exchange (Highmark BCBS). They're actually cutting premiums on average slightly next year, by half a percent. They state in their summary that "Covid19 is expected to increase claim costs in 2021"...but that's all they have to say about it. The full actuarial memo includes an extensive section about the COVID-19 impact factor...but the numbers/percentages are all redacted:

The Idaho Insurance Dept. has posted the preliminary rate filings for the 2021 Individual and Small Group markets:

The Department of Insurance receives preliminary health plan information for the following year from insurance carriers by June 1 and reviews the proposed plan documents and rates for compliance with Idaho and federal regulations. The Department of Insurance does not have the authority to set or establish insurance rates, but it does have the authority to deem rate increases submitted by insurance companies as reasonable or unreasonable. After the review and negotiation process, the carriers submit their final rate increase information. The public is invited to provide comments on the rate changes. Please send any comments to Idaho Department of Insurance.

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